NEBSA Updates - FCC Adopts Rule Changes Completing Transition of Wireless Services (including EBS) to All-Electronic Filing

The FCC on September 17, 2020 released a Report and Order in WT Docket No. 19-212, relating to its effort to transition to all-electronic filings for its wireless services, including EBS.  One the rule changes go into effect, which will be six months following the effective date of this decision (probably sometime in or around April, 2021), all EBS-related FCC filings will have to be made electronically.  In addition, all FCC communications to and from licensees (such as notice of upcoming license renewal deadlines) will be sent by email.


Under current rules, almost all EBS applications are already required to be filed electronically via the FCC’s Universal Licensing System (ULS).  However, applications for Special Temporary Authority (STA) and applications for approval of subleases had to be filed on paper because the ULS system was not set up to handle these filings.  Once these new rules go into effect, FCC electronic systems will be able to handle these filings, and electronic filing will become mandatory.   In addition, educators seeking new EBS licenses pursuant to waiver of FCC rules had to file on paper as well.  Going forward, the only opportunity to file new EBS applications will be in the context of applications filed in the EBS white space auction filing window (which will probably take place sometime mid-year in 2021), and those filings will also be made electronically.


In order to facilitate electronic communications with the FCC, the agency going forward will require all applications to include valid email addresses.  For existing EBS licenses, the FCC encourages licensees to complete administrative updates to provide current email information.